Case Explained: UNITED STATES OF AMERICA v. MICHAEL SCOTT HOOVER

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-07-28 The fourth-circuit dismissed Michael Scott Hoover’s appeal from the district court’s denial of his 28 U.S.C. § 2255 motion for lack of a certificate of appealability (COA). Under 28 U.S.C. § 2253(c)(1)(B), an appeal in a habeas proceeding is not permissible unless a COA issues, which requires the applicant to make a substantial showing of the denial of a constitutional right. The court applied the standard that Hoover must demonstrate that reasonable jurists could find the district court’s assessment of his constitutional claims debatable or wrong. After independently reviewing the record, the court concluded that Hoover failed to satisfy this requisite showing and therefore denied the COA. As a result, the appeal was dismissed without oral argument. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.